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1994, Mr. Mark telephoned to request audit reconsideration.
During a second telephone conversation on November 18, 1994, Mr.
Mark indicated that he would be providing additional information
to counter respondent’s deficiency determination. At that time,
respondent’s agent informed Mr. Mark that the last day to file a
petition with the Court was November 24, 1994.2
Neither petitioners nor Mr. Mark contested respondent’s
determinations in the notice of deficiency by filing a petition
with this Court.
On March 6, 1995, respondent assessed against petitioners
the deficiency and penalty determined in the notice of
deficiency, together with statutory interest, and thereafter
began collection proceedings against petitioners.
On November 1, 2001, respondent issued to petitioners a
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing (notice of intent to levy), pursuant to sections 6330(a)
and 6331(d)(2), pertaining to petitioners’ outstanding liability
for 1991.
On November 5, 2001, petitioners submitted a Form 656, Offer
in Compromise, to respondent. Petitioners did not check any of
the boxes under the reason for submission of the offer–-doubt as
to liability, doubt as to collectibility, or effective tax
2 Nov. 24, 1994, was Thanksgiving Day; accordingly, the
last day was Nov. 25, 1994. See sec. 7503.
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